FTC and Washington File $225 Million Amway MLM Settlement

FTC and Washington File $225 Million Amway MLM Settlement in Federal Court

The Federal Trade Commission and the State of Washington sued Amway Corp. and two affiliated training groups on September 17, 2026 in the U.S. District Court for the Western District of Washington, filing a proposed $225 million settlement the same day. No court has ruled yet.

Information last verified on September 28, 2026. This is a developing story; we update it as the record changes.

Status: Complaint and proposed stipulated final order both filed September 17, 2026 in the U.S. District Court for the Western District of Washington. The order is proposed only. It requires the court's approval and had not been entered as of September 28, 2026. Defendants "neither admit nor deny any of the allegations in the Complaint, except as specifically stated in this Order" (Stipulated Order, Findings para. 3), and no court has found any defendant liable.

Jurisdiction scope: This is a federal FTC Act case plus Washington state consumer-protection claims, filed in a single federal court in Seattle, and the proposed order's conduct terms reach Amway's United States marketing plan. It is not a criminal case, it is not a private class action, and it does not decide anyone's individual claim. For consumer class-action settlements with claim deadlines, see our consumer settlement tracker.

What Happened

On September 17, 2026 the FTC and the State of Washington filed a "Complaint for Permanent Injunction, Monetary Judgment, Civil Penalty Judgment, and Other Relief" in the U.S. District Court for the Western District of Washington against Amway Corp., also doing business as Amway North America, World Wide Group, L.L.C. and Leadership Team Development, Inc. (Compl. caption; paras. 26-28).

The FTC brought its claims under Section 5(a) of the FTC Act, 15 U.S.C. 45(a), and sought relief under Sections 5(a)(1) and 13(b), 15 U.S.C. 45(a)(1) and 53(b) (Compl. para. 1). Washington brought its claims through the Consumer Protection Division of the Attorney General's Office under the Washington Consumer Protection Act, Wash. Rev. Code 19.86, invoking Wash. Rev. Code 19.86.080 and 19.86.140 (Compl. paras. 2, 25).

The same day, the parties filed a proposed Stipulated Order for Permanent Injunction, Monetary Judgment, and Other Relief. Its caption carries Case No. 2:26-cv-3474, and the CM/ECF header stamped on the filed complaint reads "Case 2:26-cv-03474 Document 1 Filed 09/17/26." The FTC's own case page for the matter did not display a docket number as of September 28, 2026; it lists only the two documents and a case status of pending. The order's compliance-reporting section identifies the FTC matter number as 2223079 (Order sec. XIII.E).

Amway signed the stipulation through counsel at Kelley Drye & Warren LLP on August 13, 2026, and WWG and LTD signed through counsel at Kirkland & Ellis LLP on the same date; FTC and Washington counsel signed on September 17, 2026 (Order, signature pages 33-37). The signature block for the district judge is blank and undated (Order page 32).

The core allegation. The complaint alleges that Amway's products are premium priced and hard to sell to non-participants, and that the affiliated training groups instruct IBOs to buy a set volume of products each month to generate the points that drive bonuses (Compl. paras. 3-4). Quoting a 2019 slide presentation prepared by one of Amway's highest-ranking executives, the complaint alleges that new IBOs find that "[s]elling to customers is not rewarded, not taught by leaders and difficult." (Compl. para. 3.)

The FTC and Washington allege that the result is a business largely fed by its own sellers: "In 2023, for example, Amway's data indicated IBOs purchased 77 percent of the products sold by Amway." (Compl. para. 32.)

The earnings numbers the complaint pleads. The complaint alleges that in 2023 median total bonuses before expenses were $139, and that fewer than 1,600 IBOs out of more than 241,000 received $40,000 or more (Compl. para. 14). It sets out a decile table of 2023 bonus payments for the more than 241,000 IBOs who bought or sold an Amway product that year, in which the bottom decile shows $0 average and $0 median, and it alleges that the 90th percentile bonus payment was $1,756, "meaning that 90 percent of IBOs received bonuses less than that amount in 2023" (Compl. paras. 115-116). For the top 1 percent, the pleaded figures are an average of $77,887 and a median of $49,379 (Compl. para. 117).

The complaint alleges those figures sit against real costs. Annual WWG membership, audio, messaging-app and major-event costs for one person are pleaded at over $2,100, and LTD annual costs at over $1,600 to over $3,600; the complaint alleges WWG itself estimated in 2022 that a year in WWG cost one person $3,500 to $5,500, excluding Amway product purchases (Compl. para. 135). For IBOs who joined WWG in 2020 through 2023, total bonuses plus online retail margin through March 2024 are pleaded at roughly $175 to $630, with medians under $100 (Compl. para. 109); the LTD figures are pleaded at roughly $175 to $535 with medians under $100 (Compl. para. 110).

The complaint also pleads recruiting difficulty and churn: in 2020 through 2023 most IBOs failed to recruit a single IBO and the average number of recruits per IBO was less than one (Compl. para. 120), and in those years between 70,000 and 130,000 new IBOs joined while over 100,000 left each year (Compl. para. 19).

The faked-sales allegation. The complaint alleges Amway expanded a self-reporting system it called "Create a Receipt" in early 2021, which let IBOs buy products with their own cards, ship them to their own homes and then report a resale through an online form whose principal internal checks were whether the supplied cell number worked and was not already on file (Compl. paras. 209-210). It alleges Amway employees predicted the result: Amway's current Vice President of Sales observed that IBOs "will lie with receipts" and another employee called the tool "easy to manipulate." (Compl. para. 212.) The complaint alleges that purported customer-sales data then more than tripled between late 2019 and early 2022 while Amway's overall sales were flat and then declined, and concludes that Amway's "Verified Customer Sales" data "are not valid" (Compl. para. 216).

The FTC's public framing. Christopher Mufarrige, Director of the FTC's Bureau of Consumer Protection, said in the agency's September 17, 2026 press release: "Amway and its affiliates misled prospective workers with false earnings claims and then pressured them to buy Amway products they were unlikely to be able to sell." The release states that the Commission vote authorizing staff to file the complaint and stipulated final order was 2-0.

Posture matters here. The FTC's own release states the rule: "Stipulated final orders have the force of law when approved and signed by the District Court judge." As of September 28, 2026 that had not happened on the FTC's published record.

What the Law Actually Says

Section 5 of the FTC Act. The complaint recites the standard it is pleading under. Section 5(a), 15 U.S.C. 45(a), "prohibits 'unfair or deceptive acts or practices in or affecting commerce'" (Compl. para. 218). The complaint then states the deception theory it uses: "Misrepresentations or deceptive omissions of material fact constitute deceptive acts or practices prohibited by Section 5(a) of the FTC Act." (Compl. para. 219.)

For unfairness, the complaint recites the statutory test in 15 U.S.C. 45(n): acts or practices are unfair "if they cause or are likely to cause substantial injury to consumers that consumers cannot reasonably avoid themselves and that is not outweighed by countervailing benefits to consumers or competition" (Compl. para. 220). Count One tracks that language and applies it to the alleged incentive structure (Compl. paras. 221-223).

How the complaint frames a deceptive earnings claim. Counts Two through Four follow a two-step pleading pattern. First the complaint alleges the representation: that consumers who bought the products, training or services were likely to earn substantial income such as $40,000 or more annually, to replace a full-time income, to pay off debt or to retire early; to earn supplemental net income of several hundred or a few thousand dollars a year; or to recruit at least several new IBOs (Compl. para. 224). Then it alleges the "In truth and in fact" contradiction, including that consumers "did not earn supplemental net income, and in fact lost money or made a profit that was materially less than several hundred or a few thousand dollars after expenses" (Compl. para. 225). It concludes that the representations "are false or misleading or were not substantiated at the time the representations were made" (Compl. para. 226).

Count Three targets representations about the opportunity itself: that it is open only to a limited number of qualified applicants, that it provides direct access to mentoring from highly successful mentors, or that it provides access to mentors who do not need to work (Compl. para. 227). Count Four targets the representation that it is a legitimate business practice for IBOs to create false business records of purported customer sales; the complaint alleges that practice "is not a legitimate business practice and could expose IBOs to criminal or civil liability" (Compl. para. 231).

The Washington counts. Counts Five and Six are brought by the State under Wash. Rev. Code 19.86.020, which the complaint quotes: "unfair or deceptive acts or practices in the conduct of any trade or commerce are hereby declared unlawful" (Compl. paras. 234, 240). Count Five lists seven categories of alleged deceptive representations (Compl. para. 236), Count Six pleads unfairness (Compl. para. 242), and both allege the practices "affected the public interest" and formed "a pattern of conduct" (Compl. paras. 237, 243). The State's prayer asks for civil penalties under Wash. Rev. Code 19.86.140 "of up to seven thousand five hundred dollars ($7,500) per violation" and restitution and fees under Wash. Rev. Code 19.86.080 (Compl. paras. 238, 244; Prayer B-D).

What is not in this case. The complaint pleads no count under the FTC's Business Opportunity Rule, 16 C.F.R. Part 437, and no pyramid-scheme count; the six counts are the FTC Act unfairness and deception counts and the two Washington CPA counts described above (Compl. paras. 221-244). The complaint also pleads no employment-law claim. Amway calls the people in its program "Independent Business Owners" (Compl. para. 3), and nothing in the proposed order reclassifies them or addresses wages, so the order leaves the underlying question of worker status where it was; for background on how that status question is framed generally in the United States, see our guide to employment status and at-will rules.

The order itself also records that the complaint "charges" violations of Section 5 of the FTC Act and the Washington CPA "in the marketing, promotion, and sale of a Marketing Plan" (Order, Findings para. 2). A charge is an allegation, not a finding.

What the Proposed Order Would Require

The money. Section VIII would enter four judgments: $154,700,000 against Amway Corp.; $39,780,000 against WWG and Amway jointly and severally; $26,520,000 against LTD and Amway jointly and severally; and $4,000,000 in favor of Washington State against defendants (Order secs. VIII.A-E). The three FTC judgments total $221 million and are stipulated to be held in escrow by Kelley Drye & Warren LLP, payable to the Commission within seven days of entry (Order secs. VIII.A-C). The Washington payment is designated under Wash. Rev. Code 19.86.080 for the State's costs and reasonable attorney's fees, monitoring and potential enforcement of the order, and future enforcement of Wash. Rev. Code 19.86, payable within 30 days of entry (Order secs. VIII.E-F). The proposed order imposes no civil penalty, although the complaint had asked for one (compare Order sec. VIII with Compl. Prayer B).

Section VIII.D provides that money received by the Commission "may be deposited into a fund administered by the Commission or its designee to be used for nationwide consumer relief, such as redress and any attendant expenses for the administration of any redress fund," with a fallback to other related relief if direct redress is wholly or partially impracticable and with any unused money deposited to the U.S. Treasury (Order sec. VIII.D). Section X requires defendants to provide customer information so the Commission can administer redress, within 14 days of a written request.

The 70 percent resale rule. Section I.A.2 states: "The Marketing Plan requires that each Participant's Eligible Customer Sales constitute at least seventy (70) percent of the Participant's Monthly Product Volume." That term is defined, not aspirational: an "Eligible Customer" must be a non-participant who registers with a mobile number and name plus an email or mailing address, receives a unique purchaser ID, and buys exclusively for their own use (Order sec. Definitions J). An "Eligible Customer Sale" requires, for offline sales, reporting to Amway within 72 hours with the purchaser's name and mobile number, the date, products and quantities, the amount actually paid, taxes, shipping and the payment mechanism, and it requires Amway to send an Amway-identified receipt within 24 hours (Order sec. Definitions K).

Recruiter compensation and recruiting gates. Section I.A.3 reduces the business volume credited both to a participant who misses the 70 percent threshold and, after that participant's first six full months, to that participant's upline in the same proportion. Appendix A supplies the formula: the percentage of business volume credited equals the participant's eligible-customer-sales percentage divided by 70 percent, so 35 percent of volume in eligible customer sales yields 50 percent credit and zero yields zero. Section I.A.4 bars upline business-volume credit for a new recruit's unsold product purchases during that recruit's first six full months. Section I.B bars enrolling anyone new unless the upline has made eligible customer sales to at least three different eligible customers and has completed the order's training.

Reporting, receipts, refunds and training. The receipt and prompt-reporting terms sit in the Eligible Customer Sale definition described above, including the actual amount paid rather than a suggested list price. Section I.D entitles participants and former participants to a full refund, including tax and fees, of unopened and unsold or currently marketable and unsold product bought in the previous 12 months, with Amway paying return shipping and notifying participants of the right. Section I.C requires Amway to train all participants within six months of entry, and new participants within three months of enrollment, on eligible-customer-sale and reporting rules, the consequences of falsifying sales, the fact that samples, donations and gifts are not eligible customer sales, buying only what the participant expects to sell, permissible representations, refunds, complaints, and the order's requirements.

Termination for faked sales. Section III restrains defendants from failing to take corrective action when they know or should know a participant faked or misreported sales, registered a customer without consent or with bad contact details, or paid a customer for a purported purchase. Section VI.B sets the escalation: for a participant at Platinum level or above who reported a sale that did not occur, reimbursed a purported customer, or instructed others to do so, Amway "shall terminate the Participant's contract" after investigation; for other participants, a suspension of at least one month plus retraining, and termination on a second instance; and for an approved provider that failed to report such conduct, Amway "shall promptly and permanently revoke" that provider's authorization. Section VI.D requires clawback of benefits paid on non-compliant transactions.

Independent audit. Section VII bars defendants from providing any benefit to any participant unless a third-party auditor is appointed within 120 days of entry. The auditor collects eligible-customer-sales, customer, enrollment and benefits data, reviews it "using methods and criteria selected by the Commission and the State," may survey customers and participants, reports annually to the Commission and the State for 10 years, serves at Amway's expense, has "full, real-time access" to relevant records, and maintains a participant reporting database that defendants may not access (Order secs. VII.A-F).

First-year fees, misrepresentation bans and monitoring. Section II.C restrains defendants, which by definition includes WWG and LTD, from "[c]ollecting payments of any kind, directly or indirectly, from Participants during their first twelve (12) months as Participants," except payments for product purchases permitted by the order. Section II.A and II.B bar instructing or encouraging participants to report sales that did not occur or to buy specific numerical amounts of product for reasons other than eligible customer sales. Section IV permanently bars a long list of misrepresentations, including characterizing gross payments as profits or net income, claims about the likelihood of substantial earnings or of recruiting, claims about mentors' workload or financial success, and lifestyle representations. Section V permanently bars earnings representations unless accompanied by a clear and conspicuous disclosure that, among other things, never gives average payment information "without corresponding median information" and never gives income figures without accurate expense information including Amway fees, cost of goods sold and approved-provider payments (Order secs. V.A-B).

Duration, notice and reporting. Section I.F sets the effective date for Sections I.A, I.B, I.D and I.E at nine months after entry and keeps Section I in effect for 10 years; Sections II, III and VI run 10 years; Sections IV and V are permanent. Section XI requires Amway, within seven days of entry, to email the Appendix B notice to everyone in the United States who was a participant at any time between January 1, 2021 and the date of entry, with first-class mail follow-up for failed deliveries, and bars adding anything to that notice. Appendix B's text tells recipients that "Amway, WWG, and LTD do not admit or deny these allegations" and that many changes "will not be implemented immediately." Sections XII through XV add order acknowledgments, a sworn compliance report one year after entry, compliance notices for 10 years, 10 years of record creation with five-year retention, and compliance-monitoring discovery, including the FTC's and the State's authority to pose as consumers. Section XVI.B lets the State seek civil penalties "of up to $125,000.00 per violation pursuant to Wash. Rev. Code 19.86.140" if the court finds by a preponderance that defendants violated a material condition of the order.

Analysis: Why This Matters

The following is analysis from the Recording Law Editorial Team.

The striking thing about this filing is not the headline number, which the FTC itself calls "the largest monetary recovery obtained in an FTC action against a multilevel marketing company, nearly all of which will be used as redress to consumers" (FTC press release, September 17, 2026). It is that the conduct relief is built around a definition rather than a promise.

The complaint alleges Amway already had a 70 percent rule and that it was hollow in two specific ways: the rule let a "reasonable amount" of product bought for personal or family consumption count toward the 70 percent (Compl. para. 199), and a later revision effectively lowered the real bar to 60 percent by letting 10 percent of monthly volume count as samples or demonstrations (Compl. para. 202). The proposed order responds at the level of definitions. "Eligible Customer" excludes participants and entities participants control, requires registration and a unique purchaser ID, and requires purchase for the customer's own use (Order sec. Definitions J). "Unsold Product Purchases" expressly captures product "given away as samples or personally consumed by the Participant" (Order sec. Definitions T). A rule that cannot be satisfied by self-consumption or sampling is a different rule from the one the complaint describes, whatever its percentage.

The second structural feature is that the order attaches consequences upward. Under Section I.A.3, a recruiter's credited business volume falls in proportion to a recruit's shortfall after the recruit's first six full months, and under Section I.A.4 the recruiter gets no credit at all for a new recruit's unsold purchases in those first six months. The complaint's own arithmetic explains why that matters: it alleges that in WWG's standard presentation, less than $1,000 of a $40,000 illustration came from retail margin and more than $38,000 came from downline recruits, so 96 percent of the illustrated revenue came from recruits (Compl. para. 17). Changing which transactions generate upline credit goes at that structure directly.

Third, the verification problem the complaint describes is answered with third-party access rather than self-reporting. The complaint alleges internal predictions that self-reported sales would be faked (Compl. para. 212) and a receipt tool that sent nothing to the purported customer (Compl. para. 210). The order requires Amway to send an Amway-identified receipt within 24 hours (Order sec. Definitions K.3), requires the actual price paid, and installs an auditor with real-time data access, survey authority and a participant reporting channel defendants cannot see (Order secs. VII.A-F). Those are auditable facts rather than attestations.

Finally, the disclosure terms are worth reading closely by anyone who writes earnings copy in any industry. Section V bars presenting average payment information "without corresponding median information" and bars income figures unaccompanied by accurate expense information. The complaint explains the gap that rule closes: it alleges Amway's published income disclosure put 2023 "average earnings" for IBOs at Founders Platinum and below at $841 while the pleaded median total bonus was $139 (Compl. paras. 14, 118). The same asymmetry appears in ordinary retail contexts, which is why comparable claims show up in private litigation over advertised savings and product performance, such as the deceptive discount pricing settlement in Chiechi v. Albany Park and the Traeger wood pellets false-advertising settlement we track.

What this filing does not do is decide anything. The defendants neither admit nor deny the allegations (Order, Findings para. 3), the judge's signature line is blank (Order page 32), and we express no view on whether the court will enter the order or on how any other matter will come out. Note also that the complaint's factual allegations carry an unusual forward effect if the order is entered: Section IX.B provides that the facts alleged "will be taken as true, without further proof, in any subsequent civil litigation by or on behalf of the Commission or the State," including enforcement and bankruptcy-nondischargeability proceedings.

How This Affects You

If you were an Amway IBO. The proposed order does not create a claim form, and the FTC has not opened one. The FTC's press release states only that "[i]nformation on the FTC's redress program for this case will be provided at a later date." The order provides that money received by the Commission may go into a fund "to be used for nationwide consumer relief, such as redress and any attendant expenses for the administration of any redress fund," and that if direct redress is wholly or partially impracticable, or money is left over, the Commission may apply the remainder to related relief, with anything unused going to the U.S. Treasury (Order sec. VIII.D). The FTC's release says the judgment is one "nearly all of which will go to IBOs recruited by WWG and LTD who lost money." Nobody can tell you from these two documents whether any particular person will receive a payment or how much, because the order does not set per-person amounts and the administration details do not exist yet on the public record.

Watch for scams in the meantime. A large publicized settlement reliably draws imitators, and the order requires Amway to send a single notice in the Appendix B form, by email within 7 days of entry and by first-class mail to anyone whose email bounces, with the instruction that "[n]o information other than that contained in Appendix B shall be included in or added to the notice" (Order sec. XI). The FTC's case page is the agency's own publication point for this matter. If a message asks for a fee, a Social Security number or bank details to release an FTC payment, that is not how the order works; our identity theft and consumer-scam guide explains the general pattern.

If you currently participate in the program. The order's own notice tells participants that many changes "will not be implemented immediately," and the text bears that out: Sections I.A, I.B, I.D and I.E would take effect nine months after entry, training must happen within six months of entry, and the auditor must be appointed within 120 days (Order secs. I.C, I.F, VII, XI). The refund right in Section I.D, if entered, reaches unopened and unsold or currently marketable and unsold products purchased in the previous 12 months.

If you are researching any earnings opportunity. The documents themselves are the useful artifact here. The complaint's decile table (Compl. paras. 115-117) and the order's disclosure rules (Order sec. V) together show what the FTC treats as the relevant comparison: median rather than average, and revenue net of the cost of product and training.

This article is general information about a filed federal case. It is not advice about anyone's situation, and it does not tell you what to do about your own participation, taxes or potential claims.

This is general legal information, not legal advice. It describes a civil enforcement action filed by the Federal Trade Commission and the State of Washington in the U.S. District Court for the Western District of Washington, verified against the FTC's published complaint, proposed stipulated order and press release as of September 28, 2026. Federal and Washington consumer-protection law is the jurisdiction discussed here, and nothing above is an assessment of any individual's rights, eligibility or obligations. For advice about your own circumstances, consult a lawyer licensed in your jurisdiction.

Related articles

• Consumer class-action settlement tracker
• Chiechi v. Albany Park deceptive discount pricing settlement
• Traeger wood pellets false-advertising settlement
• Identity theft and consumer-scam guide
• US employment status and at-will rules

Last updated: 2026-09-28. This is a developing story; details verified as of 2026-09-28.

Frequently Asked Questions

Is the Amway settlement final?

No. As of September 28, 2026 the $225 million order is a proposed stipulated order filed on September 17, 2026 in the U.S. District Court for the Western District of Washington. The judge's signature line is blank (Stipulated Order, page 32), and the FTC's own release states that 'Stipulated final orders have the force of law when approved and signed by the District Court judge.' The FTC case page listed the matter as pending.

Did Amway admit that it broke the law?

No. The order's findings state that 'Defendants neither admit nor deny any of the allegations in the Complaint, except as specifically stated in this Order,' and that only for purposes of the action they admit the facts necessary to establish jurisdiction (Stipulated Order, Findings para. 3). The Appendix B notice Amway would send to current and former IBOs repeats that they 'do not admit or deny these allegations.' No court has found any defendant liable.

How is the $225 million divided?

Section VIII of the proposed order enters $154,700,000 against Amway Corp., $39,780,000 against World Wide Group and Amway jointly and severally, $26,520,000 against Leadership Team Development and Amway jointly and severally, and $4,000,000 to Washington State under Wash. Rev. Code 19.86.080 for the State's costs and fees, monitoring and future enforcement. The three FTC judgments are payable within seven days of entry and the Washington payment within 30 days.

Will Amway IBOs get refunds or redress payments?

The public record does not answer that yet. The FTC's September 17, 2026 press release says only that information on its redress program 'will be provided at a later date,' and that the judgment is one 'nearly all of which will go to IBOs recruited by WWG and LTD who lost money.' The order says money received by the Commission may fund nationwide consumer relief including redress, and that if direct redress is wholly or partially impracticable the Commission may apply remaining money to related relief, with anything unused deposited to the U.S. Treasury (Stipulated Order sec. VIII.D). Separately, Section I.D of the order would give participants and former participants a refund right for unopened and unsold or currently marketable and unsold product bought in the previous 12 months. That provision would not take effect until nine months after entry (Order sec. I.F.1).

Did the FTC call Amway a pyramid scheme?

The complaint does not plead a pyramid-scheme count. Its six counts are one unfairness count and three deception counts under Section 5 of the FTC Act, 15 U.S.C. 45(a) and 45(n), plus two Washington Consumer Protection Act counts under Wash. Rev. Code 19.86.020 (Compl. paras. 221-244). The complaint also pleads no count under the FTC's Business Opportunity Rule, 16 C.F.R. Part 437.

What would actually change for IBOs, and when?

If the court enters the order: eligible customer sales must be at least 70 percent of a participant's monthly product volume, with reduced business-volume credit below that threshold and proportionate reductions for the upline after a recruit's first six full months (secs. I.A.2, I.A.3, Appendix A); a participant cannot enroll anyone new without sales to at least three different eligible customers plus completed training (sec. I.B); defendants cannot collect any payment from a participant during the first 12 months except for permitted product purchases (sec. II.C); and Amway must terminate a Platinum-or-above participant who faked sales (sec. VI.B.1). Sections I.A, I.B, I.D and I.E take effect nine months after entry; training is due within six months; the auditor must be appointed within 120 days.

What is the case number and where can the documents be read?

The stipulated order's caption reads Case No. 2:26-cv-3474 and the CM/ECF stamp on the filed complaint reads Case 2:26-cv-03474, both in the U.S. District Court for the Western District of Washington. The FTC's case page for the matter did not display a docket number as of September 28, 2026, but it hosts both the complaint and the proposed stipulated order, and the order gives the FTC matter number as 2223079 (sec. XIII.E).